TRC Publishes Guidance on Environmentally Sustainable Telecom Infrastructure

In 2025 the Cambodian authorities articulated a series of incentives for green telecommunications infrastructure. The incentives aim to encourage operators, tower companies and other stakeholders to reduce the environmental footprint of their networks, to invest in renewable energy at network sites and to adopt equipment and operational practices that support broader sustainability objectives.

The incentives are relevant to mobile network operators, tower companies, data centre operators, equipment vendors and, indirectly, to enterprise customers with sustainability commitments that extend to their communications services.

The incentives reflect the growing recognition that telecommunications infrastructure is both an enabler of a lower-carbon economy and a significant consumer of energy in its own right. Green telecommunications supports climate objectives by reducing emissions from network operations, by enabling remote working and other low-carbon activities and by contributing to the resilience of essential services in the face of climate-related risks.

The framework aims to accelerate the deployment of solar power at rural sites, the use of efficient equipment, the responsible management of end-of-life equipment and the adoption of design practices that consider environmental impact alongside performance and cost.

Rural and off-grid network sites have historically depended on diesel generators, with significant costs, emissions and logistical burdens. The incentives support the deployment of solar power, hybrid systems and battery storage at such sites, with the objective of reducing dependence on diesel and improving reliability.

For urban sites connected to the grid, incentives may support the use of renewable electricity, energy-efficient equipment and cooling systems, and arrangements to reduce peak demand. Coordination with electricity providers and with local authorities may be necessary to fully realise the benefits.

The incentives encourage the use of energy-efficient network equipment, including base stations, transmission equipment and cooling systems. Modern equipment typically offers significant efficiency gains over older generations, so equipment renewal programmes can be designed to combine performance improvements with reductions in energy consumption.

End-of-life management is another important dimension. Equipment that is retired should be recycled or disposed of in an environmentally responsible manner. The incentives support arrangements with recycling providers, cooperation with equipment vendors on take-back programmes and appropriate handling of hazardous components.

Shared infrastructure typically has a lower environmental footprint per unit of service than duplicated infrastructure. The green incentives complement the passive infrastructure sharing policy by reinforcing the environmental benefits of co-location, of shared backhaul and of coordinated deployment. Rationalisation of legacy infrastructure that is no longer needed can also reduce ongoing environmental impact.

For tower companies, the incentives support investment in modernised sites, in renewable energy systems and in operational practices that minimise environmental impact. For operators, the incentives support decisions to prefer shared solutions where feasible.

Data centres and cloud services are significant energy consumers, and their environmental footprint is influenced by design, location, cooling arrangements and energy sourcing. The incentives support investment in data centre efficiency, use of renewable electricity and adoption of design practices that reflect the specific climatic conditions of Cambodia.

For cloud service providers, cooperation with local energy providers, transparency about environmental performance and engagement with sustainability standards support alignment with the incentives and with the expectations of enterprise customers.

The incentives may take a number of forms, including favourable treatment in permitting, access to concessional finance for qualifying investments, cooperation with international climate finance mechanisms and recognition in public procurement. The specific arrangements are expected to develop over time and to be adapted to the maturity of the market.

Providers seeking to take advantage of the incentives should engage with the relevant authorities, prepare well-documented proposals and demonstrate how the proposed investments contribute to the strategic objectives. Cooperation with equipment vendors, energy providers and financial institutions supports the design of workable arrangements.

As green claims become more important commercially and to public authorities, reporting and verification take on greater significance. The incentives contemplate that providers will report on the environmental performance of their networks, drawing on recognised methodologies, and that verification arrangements will provide credible assurance about the accuracy of the reports.

Providers should invest in the systems and processes needed to collect environmental data, to calculate relevant indicators and to prepare reports that can withstand scrutiny. Alignment with international reporting standards can support both the incentives and broader sustainability engagement with investors and customers.

Enterprise and public sector customers with sustainability commitments increasingly expect their suppliers, including telecommunications providers, to support their objectives. The incentives create a framework within which providers can demonstrate their environmental credentials and can offer services with lower embedded environmental impact.

Contractual arrangements can reflect these considerations, including through commitments about the sourcing of energy for services delivered to the customer, about environmental reporting and about cooperation on shared sustainability initiatives.

For providers, the incentives call for integration of sustainability objectives into network planning, procurement, operations and reporting. Governance arrangements should ensure that decisions about investment, equipment selection and energy sourcing reflect environmental considerations alongside performance and cost.

For enterprise and public sector customers, the incentives support engagement with providers on environmental matters, including in procurement processes and in the design of long-term contracts.

Lex Civora advises telecommunications providers, tower companies, data centre operators and enterprise customers on the interpretation and application of the green infrastructure incentives, on the negotiation of arrangements to take advantage of the incentives and on the alignment of sustainability initiatives with the broader legal and regulatory framework.